This General Election, please campaign locally to help STOP the badger culls.

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It’s just three weeks until polling day for the General Election. We need badger supporters to step up once again, and  to alert parliamentary candidates to the ongoing outrageous badger culls. There are two things to do:

Firstly contact your constituency candidates and ask them if they will stop the culls, if they are elected. You can find out who they are here. The Green Party have said they will stop badger culling, and Labour say they will “work with farmers and scientists on measures to eradicate Bovine TB, protecting livelihoods, so that we can end the ineffective badger cull”.  Please ask them all what their plans are and make sure they know that all forms of culling should stop from July 5th, with all existing licences revoked.

Secondly, please try to attend hustings. These are the political meetings that are held locally in your constituency, where you can meet your candidates, supply relevant information and ask them questions. Find out  where and when the hustings meetings are and make every effort to attend. Click HERE for access to a leaflet that can help give you guidance with facts about badger culling, carefully prepared by a team of dedicated badgerists from around the UK. You can print it out double-sided on A4, then guillotine in half to make A5 leaflets. (You may have to print on one side of the paper first, then reload it in the paper cassette the other way up & run through the printer again).



Good luck in your constituency. We hope newly elected MPs will be caring and compassionate and understand that on badger culling, much science has been questionable or misrepresented to promote badger culling.

We must stop the Cruel, Expensive culls. They Just Don’t Work.

Defra’s zombie killing machine won’t stop

DEFRA don’t want to vaccinate badgers, they want to keep killing them, against advice from Natural England.

As the first badgers of summer 2024 are being killed outright by a shot to the heart, or scream and die slowly in pain, a Freedom of Information response released on 31st May has revealed a morass of Government confusion. Communications between Defra and Natural England  from April and May of this year show DEFRA contriving to carry on culling. By aligning with the views of its highly controlled ‘BTB Partnership’, and stalling the promised badger vaccination programme, that they have had four years to prepare for.

Dr Peter Brotherton’s (Director of Science at Natural England) advice in April, (see here), a response by Defra in early May (here), and final decision by NE (here) tell the story. NE’s response to the recent policy consultation (here), is also very revealing. Brotherton gives NE’s view on Supplementary Badger Culling (SBC) that are done after 4-years of Intensive culling, is that badger vaccination should be the best option to promote, based upon his view of the available scientific evidence :

“I can find no justification for authorising further supplementary badger culls in 2024 for the purpose of preventing the spread of disease and recommend against doing so.

However, on 1st May, Sally Randall who is the Director General for Food, Biosecurity and Trade for DEFRA responded saying:

“The experience of the last three years has shown that whatever changes are made to disease control, those most affected by the disease, must have confidence in both the process and the trajectory. Changes need to be carefully timed and communicated, whilst balancing a range of potentially opposing views. Any abrupt changes to policy would seriously undermine our ability to engage constructively with the industry on future disease control interventions.”

The letter included an Annex A. with advice from APHA and the Chief Veterinary Officer, stating that Defra’s view was that SBC should continue until badger vaccination was fully viable, and that would take an unspecified amount of time. DEFRA said it had not gone far enough with preparations and that there was no financial capacity to promote it. They implied that farmers didn’t want it either. Then just two days later on 3rd May, Oliver Harmar, Natural England Chief Operating Officer, responsible for badger cull licensing at Natural England, decided to grant nine new Supplementary Badger Control licences and to authorise seventeen existing SBC licences in 2024, the decision having been passed by Tony Juniper and the NE Board. The licences were issued around mid-May.

But of equal importance, Brotherton made the following remarks:

“As I have said in previous advice, much greater effort is needed to raise awareness of the disease reduction benefits of the alternatives to culling among the farmer community, in my opinion. In this regard, it is disappointing that the recent publication by Birch et al. 2024 has been widely reported as providing evidence that badger culling reduces the incidence of bTB by 56%, when in fact the study shows the overall impact of implementing a range of bTB control measures, not culling alone. Further research to establish the relative disease reduction contributions of the different control measures is needed.”

This of course is the point made problematic by the crude and misleading ‘Abstract’ at the start of the APHA draft report (here) and following on with the published version (here). The recent Defra consultation on introducing so-called ‘targeted culling’ claimed that badger culling was responsible for herd incidence reduction, although it had no evidence of this. Brotherton is therefore disappointed by Steve Barclay, the Secretary of State for Defra and Defra Minister Douglas Miller and previous Defra Ministers. They have all seriously misled the public with badger cull claims and this is now a matter for legal consideration. Reductions in herd breakdowns could all have been down to tighter cattle testing and the accepted published peer reviewed and uncontested science on changes to herd incidence peaking and falling before badger culling was rolled out – and shown at the County level (2013-2019) suggests that this is most likely the case (see Langton, Jones and McGill 2022).

In previous High Court challenges over the future of badger culling, the ruling has been that decisions on culling can also be political decisions. If the future of badger culling is to be based on the science, then we will be seeing an end to culling very soon. Intensive, Supplementary, Low Risk Area, and Targeted culling are mistakes that should, and will be seen as such, and confined to the past.

While the disease benefit of badger vaccination is (like badger culling) not proven, the benefits of tighter cattle testing are well established. It is cattle measures done properly that will deliver the much needed bovine tuberculosis disease control for Britain and Ireland.

On 5 July the new Government must focus on advanced cattle testing, quarantines and lockdowns and consign badger culling to history, where it belongs.

Defra scraps pre-election badger cull ambition

There has been a positive step forward.

Defra have responded this afternoon about how they are handling Tom Langton’s legal challenge to the recent badger culling consultation, that closed just before the General Election was announced last week. A Pre-Action Protocol letter challenged the lawfulness of Defra’s  ‘targeted badger intervention’ policy consultation for several reasons and today Defra were responding about their intentions in the weeks to come.

Defra said they are “continuing to analyse consultation responses with a view to putting proposals for a decision on this policy to the incoming government after the election.”

This is good news at least in the short term. A new policy will not be put in place by the current Conservative government. But it also implies that Defra may seek to defend the claim that the consultation was unfair, which is disappointing.

Defra also say that they want an extra two weeks to consider the PAP letter, but we will learn their position on 14th June. Defra should drop the consultation,  recognise its failings and accept that badger culling has no future at all in bovine tuberculosis control in cattle.

STOP PRESS

 

In March Rishi Sunak seemed intent on killing all the badgers by giving sweeping powers and a very free hand to the Chief Veterinary Officer to cull up to 100% of badgers in areas she deemed appropriate. Now he has now called a General Election for July 4th , which means that Parliament will be prorogued tomorrow, 24 May, and dissolved on 30th May. The public will vote 25 working days later. Government actions are limited during the election campaign ‘pre-election period’  that was previously known as ‘purdah’. The shut-down helps to ensure that public money is not used to support campaigning by the political  party in power, and to maintain the impartiality of the civil service.

This could be good news for bovine TB control  and badgers if the outcome is that the government  does not let the National Farmers Union dominate and dictate its actions, as it has for so long.

30th May is also the date by which DEFRA must respond to the Pre-Action Protocol (PAP) letter issued on 16th May that was supported and funded by The Badger Crowd.  We should soon learn what Defra intends to do in response. What are their options? And what will the government that takes over in six weeks’ time be likely to do?

Defra could accept that the consultation was botched and shut it down by doing nothing. The PAP letter gives them the option to withdraw the proposals or to reconsult, which would now be after the election. This is likely to mean that it  would now receive a new political steer.  The PAP letter also asks that no future proposals are decided before a legal challenge is  disposed  of – i.e. dismissed or heard in a court trial.

Defra could accept that the consultation  was rushed out too hastily without proper consideration, just in case of an early general election and so needs a total rethink. Alternatively, they could try to rush a formal response through next week, so that the principle of  ‘targeted culling’  is established before a change of government. They could either keep Natural England licensing or continue to re-badge the NE Bristol licensing office as one of  Defra’s own. However, this now looks like a very tall order in the limited time available.

What will the Lib Dems do? Like Labour they will be looking to take back and win over seats in the southwest, in areas where livestock farming dominates the landscape. Not making badger culling a big election issue looks likely to remain important to both political parties, and both are likely to remain tight-lipped. Labour has previously pledged to scrap badger culling, and are the party most likely to hold power next.

Whoever wins the election will be responsible for the bigger challenge of putting in place the appropriate cattle-based measures that will drive down the disease that is embedded in chronic cattle herds. This will have to involve tough restrictions that will cause the beef and dairy to contract. This is something the NFU have resisted and put off, while at the same time holding out a hand for compensation. It’s no easy choice for whoever wins the election. Scrapping badger culling should be an easy decision, but what will really count is making the necessary changes to  testing using the expertise pioneered by  Dick Sibley in Devon. That might mean scrapping the ineffective BTB Partnership and setting up something that understands the science of the problem, and how to address the problems without reverting to the lay-beliefs of many rural cattle  vets, based upon dogma and misinformation from government.

The winning government might also instigate a rapid review of bovine TB control needs early on. Whatever happens next, the actions of Badger Crowd have again been highly effective. Legal letters sent to Defra on 19th and 28th March demanded an extra 3 weeks of consultation time, which gave the legal team time to submit the PAP challenging the legality of the consultation. All of the three legal challenges supported by Badger Crowd since 2017 have been accepted for trial by the High Court, and it would be great if a fourth substantive hearing is now not needed. This would allow time and resources to be better spent, redeployed  protecting badgers and dealing with bovine disease in meaningful ways.

Yet again we can dare to  find optimism for the future. Let’s hope that it won’t be dashed as it has been so often over the last ten years. The science is clear that badger culling does not work and plays no role in reducing infections in cattle herds. It has to stop. It must stop.

Tom Langton who has figure headed the legal challenges since 2017 said:

“This looks very much more than the beginning of the end. We have fought hard for seven years to highlight the legal and scientific case against badger culling, with breakthroughs more recently, and exposure of actions that are not in the public interest. Of great concern has been the ‘tribal’ behaviour of civil servants and wilful blindness that shows hallmarks of both the blood transfusion and post office scandals. Yet ‘badger blame’ has been ongoing for 50 years now. Thanks to better understanding of the issues involved, we can now start to see the mistakes and misjudgements of the past. The new government will need to focus on how to lower the rates of transmission of bovine TB, much as was done with Covid-19 in humans. This will bring tough times for the beef and dairy  industry, but it has to be done to interrupt the dependency on public subsidy, stop the wide range of collateral damage to rural life and the environment that it has caused in recent decades, and finally see progress in eliminating this horrible infection”.

Thanks, and good wishes to all who have supported the Badger Crowd fight against badger culling.

WE ARE THE BADGER CROWD. WE STAND UP FOR BADGERS.

GOVERNMENT BADGER CULL CONSULTATION – NEW LEGAL ACTION UNDERWAY

A pre-action protocol letter regarding proposals to evolve the badger control policy was sent to Defra on Thursday 16th May following closure of their extended consultation period on plans to continue badger culling using a so-called ‘targeted’ approach.

Badger Crowd has had sight of the letter sent by lawyers to Defra that challenges aspects of the consultation that ran 14th March – 13 May 2024, as unfair.  A large number of problems are identified including:

  • Misleading and inadequate information regarding badger culling efficacy
  • Failure to provide information on ecological impacts of the policy
  • No meaningful information on economic impacts of the policy

The action is being taken by conservation ecologist Tom Langton who since 2017 has been given permission for and completed three previous judicial reviews (JR’s) supported by Badger Trusts and Groups, wildlife charities and caring individuals. These JR’s have exposed details of the badger culls that have been vital for public understanding of the rationale behind and operational decisions surrounding badger culling, although only preventing culling in a few nature reserve areas to-date. As a professional scientist and with others, he has published since 2019, details of badger culling efficacy and bovine TB trends in England. One of these publications in particular, Langton, Jones and McGill, March 2022 in Veterinary Record, is directly refuted by two government scientists in the recent consultation, but yet again without any supporting evidence. The Government agency APHA have published a paper in front of the new consultation that is weak; it lacks any comparison between culled and unculled areas and states that there is no way to tell whether badger culling is having an effect on measured levels of disease. Despite this, wording in the abstract of the same paper, both as a preprint and as published, has led the Secretary of State and the Defra Minister to make unsubstantiated claims before (since 2022) and within the consultation, saying that APHA data shows badger culling works. This is a very basic misreading of the available published and peer-reviewed science.

Tom Langton said:

“It is with deep disappointment that Defra forces us back towards the courts to seek redress on the ‘badger control policy’, because the current consultation has created a confusion that surrounds safe and informed consideration of the best course of action for bovine TB control in cattle. Defra has not learnt from mistakes of the past and wants to u-turn the 2020 policy that aimed to phase-out badger culling. It wants to award sweeping powers to the Chief Vet to decide when and where to cull, and how many more dead badgers to add to the 230,000 mostly healthy adults and cubs already killed since 2013. This they achieve by simple misinterpretation of science and by implementing further countrywide operations that are veiled in secrecy.

Much of the confusion and misinformation in the consultation obscured public consideration of critically important matters such as rationale, ecological impacts, economic benefit and animal welfare considerations, to a point where it was simply not fit for purpose. Many of the consultations 19 questions and comment opportunities were likewise cloaked in ambiguity, to the point where response was dependent on assumptions and interpretations, so wide as to make collective and comparative analysis of them meaningless. The consultation options were narrow and miscast, appearing to be aimed at quickly pushing though a single, pre-planned approach to keep on killing badgers. This was a construction by a Ministry desperate to use public funds to support a demand that Defra has itself fostered, by blaming badgers as a key part of bovine TB epidemiology for decades, but based on flimsy evidence. The muddled thinking and bad policy needs to stop right now.

On behalf of badgers, cows and farmers I implore Defra to recognise that this consultation was flawed and should be set aside in favour of more detailed and coherent review of current needs, with new planning towards approaches that can be successful.”

The challenge asks Defra to withdraw its proposals or to reconsult in an adequate way. Meanwhile the request to Defra is that they confirm no decision will be made on consultation responses before the challenge and complaints are fully heard and concluded.

The Defra Badger Cull consultation on the ‘targeted badger intervention’ policy – where are the swerves?

The Defra consultation on more badger culling ends on Monday 13th May 2024, at midnight. Since it was launched on 14th March there has been increasing incredulity over how sketchy and confused it is. It is a classic example of how not to consult with the public over an extremely important decision on how to tackle a complex disease epidemic.

The problems are largely of Defra’s own making, with the scientific aspects of the issue particularly poorly handled. Questionable management of the bTB policy is exemplified by the ‘BTB Partnership’. This was was set up under the 2020 ‘Next Steps’ policy, after the Derbyshire badger cull licence was put on hold for a year in 2019 by Boris Johnson who fought off the NFU and announced a  move to phase out badger culling.

The BTB Partnership was set up as a group of largely cherry-picked farmers and vets, most of them it would seem wedded to badger culling, and ‘hired and fired’ by Defra who also control the agenda, with secrecy over its work, reporting and outputs. There is a blog about the shambolic Partnership here. Not surprisingly, it recommends more badger culling and tries to row back on actions that might inconvenience the beef and dairy industries, thus preventing the industry contraction that must inevitably come, but that could have been so much smaller, if done earlier.

The main problem with the consultation is that it blurts out its intention without actually consulting. It’s a bit like asking what colour your new car should be, and do you need a sunroof? But the bigger questions have already been fixed; make, model, engine size, fuel type, all decided for you. You are being asked questions about the trimmings.

So, the consultation is not at an early stage, not at a stage where the various options are reviewed and described, with a sound build up to a presentation of the top range of possible alternatives and asking you about which path to take. Instead, Bang!, this is what you get. And it is being handled in a  similar way to previous bTB consultations  only this time it is much, much worse. It looks sloppily written and rushed. Rumour has it the NFU wanted to get it in place before the general election, although it is not actually needed in 2024. The problem for Defra is that views, or perhaps expectations on the government consultation process have been changing, and this kind of approach is no longer acceptable. Witness last October the judgement in Northern Ireland that found the badger culling proposals unacceptable. Why wasn’t the lesson heeded you have to ask?

Looking specifically at factual issues, the ‘elephant in the room’ is the discovery over the last ten years that all but a few of  (SICCT) test reactors are infected. With few false positives this makes any narrative that the herd status OTFW (officially bTB Free Withdrawn) is the yardstick for eradication (or better expressed, elimination), very old thinking.

This has some unfortunate consequences, not least for the now challenged RBCT (Randomised Badger Culling Trial) which actually found no effect of badger culling when all reactors (OTFS (Officially bTB Free Suspended) and OTFW are taken into account. This should have led to Defra reviewing their approach, but ‘stick to plan’ is the order from somewhere – the farming industry? It doesn’t make sense. And it isn’t mentioned at all in the consultation. Neither is the increased frustration and louder and louder complaints by vets and test developers that the current policy is unviable and useless. Not fit for purpode. It follows the failed trend of the Republic of Ireland who have culled badgers for over 20 years. The consultation seeks endorsement without adequately, or in many cases at all, explaining its rationale and alternatives.

Further, the consultation is not adequate in explaining the progress and new development of badger vaccination and cattle vaccination. With badger vaccination, DEFRA now pull back, saying its efficacy is unknown, much as the Godfray Review did in 2018. There is no enthusiasm for it from the farmers either. They have been told since 2022 that badger culling works and a new generation of advocates for culling have developed, bringing sentiments of badger hatred to new highs on social media.

How has this happened? Well by a series of announcements, interviews and parliamentary statements by Secretaries of State and Ministers since 2022, based upon a combination of staff at Defra and its agencies telling people that badger culling works. This continued until just before the start of the consultation on the back of unpublished data, uncheckable analyses and inference trying to transmute association to causation. Same old.

The new Secretary of State in Defra’s revolving doors of sackings and appointments is Steve Barclay. No one in cabinet wants to do the Defra job. You have to deal with climate change, flooding, sewage and farm waste in rivers and on beaches and wangle ways around protecting nature as a flurry of screamingly bad diseases flourish with industrial farming.  So Barclay sets out the consultation, claiming a figure of 56% decline in herd breakdowns after four years of culling, based on the ‘before and after’ APHA paper (Birch et al published Feb 28 this year), with absolutely none of the controls of a scientific study checking causation. There is no comparison of culled areas with unculled areas. There is a blog about the problems of Birch et al. preprint here.

Using words from a rather flaky abstract, designed to please, Barclay mis-quotes and misrepresents what the paper actually says, no doubt incorrectly briefed by the hapless APHA who are desperate to find a way out of the 2020 policy car-crash and not to call the last decade out as one huge mistake. Barclay follows other politicians, Eustice, Coffey, Spencer, Douglas Miller who have groomed the farming industry to believe what they want to hear i.e. that but for the badgers the cows would be clear of bovine TB. What is irrefutable is that the influence of badger culling on bovine TB in cattle herds is unclear.

Defra seem to have gone out of their way to bias consultee’s opinion in front of their consultation. Some observers thought it had been put on hold, with the hope of a new Parliament sorting out the mess in a years’ time. The consultation fails to distinguish between the scientific opinions of a handful of Defra staff who have spent the last decade blaming badgers, and what the published science actually says and means. Not to do so is not just worrying, it is unfair and unlawful.

Why did they drop a weak bit of analysis (Birch et al. 2024 ) just in front of the consultation and weaponise it to try to force a return to mass culling? Results from Cumbria, south of Penrith, showed that cluster culling was a sham in Area 32, and cattle measures had resolved bTB in all but chronic herds before the first of the 1115 mostly healthy badgers were shot, from 2018.The independent report “A Bovine Tuberculosis Policy Conundrum in 2023” demonstrates this clearly, and the follow-up addendum produced in April 2024 confirms it.

The failure of their ‘epi-cull’ or ‘cluster-cull’ trial is too uncomfortable for them and doesn’t fit with their ‘keep to plan’ strategy, so they pretend it hasn’t happened? Then they delay the economic evaluation until later because it looks like everything done to date has been done at a financial loss, but can be fudged in four years’ time?

The confusion and lack of technical reporting on cattle vaccination, and the need for enhanced testing according to the learning from Gatcombe farm in Devon has not been mentioned at all – no options provided. Airbrushed out.

The consultation normalises the least humane option for shooting badgers without going through the difficult considerations behind that decision. This is extraordinary, given the shift to free shooting over cage shooting for cull companies that have had praise heaped upon them with offers to make their killing easier..

The executive powers that would be passed to the Chief Vet and the appointed BTB Partnership for day-to-day decisions looks like an unrepresentative, unaccountable closed shop. Methods for identifying where badgers would be culled are unformed and justified using the unsuccessful Low Risk Area model (see here and here) and the unproven intensive culling results (see here, here and here). Why was the consultation not held back until these problems had been addressed? Answer, because the trials have failed. Why does this consultation even exist if this key point is not absolutely clear for all to consider? As APHA said in 2023, there are now more questions than answers.

This consultation is an abomination. Following the failed DEARA consultation in 2023 it is unprofessional and embarrassing. We should know who is responsible for it. It is so far away from the interests of the public and industry that it must be stopped.  

Responses to consultation questions: some thoughts:

Q7. Should there be an annual cap on the number of clusters that can be licensed to undertake badger culling? 

If you answer Yes, you may be accepting that the policy is fine as long as it is limited to x number of culls per year. Don’t be misled by this trick question. It does not offer the alternative of knowing that no targeted culling should be done.

Q8. What other factors should be taken into consideration in defining a cluster under the targeted badger intervention policy?

If you suggest new factors, this may imply that you agree with the other factors suggested. 

Q10. & Q11. To what extent do you agree or disagree there should be a separation of Natural England’s statutory conservation advice from licensing decisions?

These are tricky. At face value it might suggest that you are being asked if NE need no longer fulfil its statutory nature conservation role. But that is very unlikely to happen without a change in law. What it might be asking is whether you think NE should stop licensing culls in order to distance its  advice on badger culling ecological impacts from the authorisation of killing badgers, which would be a very good thing. However the question is very general and vague. Perhaps the question supposes culling should continue (which it should not), so does agreeing to it endorse the act of culling? NE should never have taken on the role of licensing culling, it was the worst decision in its history and has seen rampant killings of around 230,000 badgers since 2013. The next question, 11, deals with whether cull licensing should go to Defra, (to join with vaccination permissions), to which the answer should be no because culling should stop.  So Natural England  who are just told to get on with it without question should stop and it shouldn’t go to Defra? It would seem sensible not answer these ones on the grounds of confusion.  Defra would love to keep licensing with NE as it gives culling the respectability of endorsement by a conservation body. Be careful how you answer this one because the question isn’t clear. It could trick people into supporting keeping badger culling responsibility with NE. It is not clear if you can use question 12 to explain your views if you have not answered questions 10 and 11 however. What a muddle.

Q12. Please give reasons for your answers to this section (optional)

Here you could make the point that Question 10 is faulty. The question does not reflect the text of the consultation adequately.  Natural England, in preparing impact assessments free of charge for cull companies and being instructed by Defra to issue licences, has lost its supposed  independent role. NE has taken direction from and rubber-stamped Defra and the CVO’s instructions to issue licences, and for the NE Chief Scientist to describe culls as successful whether or not minimum cull targets are met.  And on an uncorroborated assumption that Defra’s badger culling policy has an disease benefit, which it has consistently failed to show.

Q13. Do you have any comments on the Information for Applicants at Annex B for carrying out the culling part of a targeted badger intervention policy? (optional)

This information is inappropriate given the unfair nature of the consultation.

Q15. Should animal level bTB risk information be published on ibTB?   

Yes

Q16. Please give reasons for your answer (optional).

Any information on disease risk should be publicly available.

Q17. To what extent do you agree or disagree it would be helpful to share information on where herd owners source their stock from?

  1. Strongly agree

Q18. Please give reasons for your answer (optional).

Any information on disease risk should be publicly available.

Q19. Do you have any other comments? (optional)

Here is your chance to offer your full view.

This consultation is an utter shambles and should be withdrawn. It is thrown together, unfair and misleads on multiple counts. It avoids providing essential background facts and leads those answering questions into endorsing ill-described proposals. This consultation will be challenged and measures are already in place for that to happen.

WE ARE THE BADGER CROWD

 

 

 

 

 

Cracks appear at DEFRA

Badger Cull Consultation extended by 3 weeks to 13 May

At around 5.00pm yesterday (19th April) Badger Crowd was sent Defra’s ‘stakeholder’ message that the badger cull consultation has been extended by 3 weeks. Due to end on Monday 22nd April, it will now finish on 13th May. One legal letter was sent to Defra on 19th March and then two on the 28th March this year, stating specifically that the 5 week consultation period was too short and that an 8 week period would be appropriate.  Defra consultations are often eight weeks long.

Although a three week time extension has been granted, the three week delay in responding to the letter and agreeing it means this still does not provide an adequate response time. Defra just doesn’t get it. 

One of the letters also pointed out the misinformation and lack of detail on aspects of the consultation document. Two long letters were also received from Defra yesterday (19th) and are now under the legal microscope.

Legal pressure from our friends at Badger Trust and Wild Justice, together with their ‘survey monkey’ poll of respondents, illustrates problems with interpretation of the consultation. Extra time will give Defra more time to reflect on how muddled their consultation truly is.

Other voluntary groups are still considering what advice to provide to individuals wanting to write to Defra about the consultation, and we will report further on this as it is made available.  It is still difficult to advise on the best way to complete the consultation, because of the lack of information provided, its limited scope, the misleading content including wrong use of science and the wording of the questions which does not allow adequately for views to be expressed.

Defra’s consultation is a mess and they know we know it’s a mess. They know it’s a big mess. Thanks again to the 700 of you who have joined the Badger Crowd and are supporting the fight for justice for badgers.

We are the Badger Crowd.  We stand up for Badgers.

*** URGENT *** IMPORTANT ***

Badger Cull Consultation Advice

There is now just a little over a week left to comment on the Defra consultation on what it wants to do next to badgers in the name of bovine TB control in cattle. As you probably know, the consultation is inaccurate and very badly justified.  Consultation responses must be in before the end of Monday 22nd April. You can find the 40 page consultation document  here.

You can respond to the consultation from Defra’s link at the bottom of the consultation page. However, the questions are loaded in favour of a U-turn to allow endless widespread badger culling, contrary to the promises of the Defra policy direction in March 2020. If you do not want to follow this limited survey, you can send your own a personal comments on the consultation to bTBengage@defra.gov.uk

If you do this, be sure to read the consultation carefully and make your views known.

What are other organisations saying?

Protect the Wild as an organization are calling the whole thing a sham and not fit for a response for a range of reasons that you might like to read:

  • See here
  • They have a petition here signed by over 8,000 people in just a few days.          

Legal eagles Wild Justice are doing a poll of views on certain aspects to follow up legal letters to Defra. They are running a questionnaire about the Defra consultation. This needs to be responded to TODAY 15th APRIL. You have to answer a few initial questions, then read the consultation and finish the questionnaire – it takes about 20 minutes.

Legal letters sent to Defra by Badger Crowd and Badger Trust & Wild Justice have not been responded to promptly, and responses are likely to be made one working day before the consultation closes. This is all part of a ploy to railroad one of the biggest decisions in the history of badgers in five weeks only. Based on loaded language and cause-arguing designed to mislead. The way this is being handled is disgraceful and a new low point for Defra. It is hoped that they will withdraw the consultation this week, as common sense dictates. We cannot rely on this however.

Don’t forget to ask any organisations that you support what they are doing about the consultation. A joint statement by the main NGOs is anticipated in the days to come. This is late in  the day, but the complexities of the misinformation and short consultation period  are all part of normalising a cruel, illogical, unscientific and needless shooting of badgers.

Help Stop the Badger Cull U-turn

Kamikaze bovine TB consultation – will it crash and burn?


On Thursday 28th March 2024 two solicitors’ letters were sent to the government. They express grave concerns over aspects of the Defra five-week badger culling consultation that began on 14th March, and attempts to bring about a policy u-turn on the phasing out of badger culling.

As readers may be aware from our recent blog, there is so much wrong with the proposal that it is hard to know where to start. Put simply, the Chief Veterinary Officer, currently Christine Middlemiss who is based at the Animal and Plant Health Agency (APHA) would be given sweeping powers to designate as many new cull areas as she and apparently a group of mostly farmers and cull companies think fit. This would be based upon currently obscure assumptions about how cattle herds have caught bovine TB in any area, yet with the finger wrongly always pointing at badgers.

Future decisions on initiating culls seem to rest around whether badgers share the same countryside areas (mostly they do because of the pasture landscapes) and whether they have the same bTB strain as the cows (mostly they don’t, according to the ‘Badgers Found Dead’ Edge and Low Risk Area surveys). Even if they do, an infected cattle herd may rapidly cause infection of the landscape, including many wild mammal species.

These decisions, to be made behind closed doors, will prevent the promised policy direction to ‘phase out’ badger culling. This phase-out  said that the last cull authorizations would be for 2025, other than in ‘exceptional’ circumstances (we continue to oppose these ongoing intensive culls). But the new consultations would permit an unlimited number of ‘cluster’ cull areas across the whole of England. There would be unlimited badger shootings, over an up to seven month period annually, each year decimating healthy badgers in the hope of killing a handful of infectious ones. Totally unacceptable.

‘Cluster’ culling looks very much like the failed Low Risk Area, so-called ‘epidemiological’ culling, which has killed so many badgers in the Cumbria pilot  without demonstrable effect (see ‘A bovine tuberculosis policy conundrum in 2023‘, chapter 5.). They are trying not to call cluster culling ‘epi-culling’ because of these failures.

What has become clear is that Defra are keen to muddle the effects of tighter cattle testing and movement control  by saying that badger culling has contributed to the well-known reduction in number of herds being withdrawn from trading. But there is no scientific evidence of this, only good evidence that badger culling has shown no effect. Yet Defra and their agency APHA remain in denial. They claim in the consultation that a peer-reviewed published academic study finding no disease benefit is flawed, yet cannot provide the data or any analysis to prove their point. After two years, their public outburst is as useless as it was in March 2022,  when their muddled attempts to undermine published science (the first attempt was withdrawn) came out.

Badger Crowd is in touch with Badger Trust and Wild Justice over a range of concerns over the lack of essential information for fair consultation. Responses from government so far have shed no light on questions asked.

Deadlines are coming up and further legal work is necessary, so an initial fundraiser was launched on Monday 1st April on the Crowd Justice website to fund the Badger Crowd legal work. Our fundraising target was reached by April 11th and the fundraiser has now been closed. Thank you very much to all who have supported. If we are advised by our legal team that we have good grounds to seek a Judicial Review, we will need to launch another fundraiser to cover the costs of this. Thank you for your support.

We are the Badger Crowd. We always stand up for Badgers.

Defra Badger Cull Consultation

What does it say and mean?

On 14th March, Defra launched a new consultation:

“Bovine TB: Consultation on proposals to evolve badger control policy and introduce additional cattle measures”

A five week consultation period ends on 22 April, so here is a digest of what is proposed. It’s is a bit long, but important if you care about truth, bovine TB control in cattle, badgers, cruelty and the squandering of public finances.

SUMMARY

This consultation is badly worded in places and the detail is hard to comprehend. It appears unrealistic in terms of scale and implementation. The questions asked in this consultation are minimal and generally loaded towards the respondent agreeing with the described process to keep on killing healthy badgers into the future.

The consultation is founded on the incorrect interpretation of a new study Birch et al. 2024, which itself is in need of revision. The robustness of the new study is open to question, and aspects of it are now being queried with the Minister and the authors.

Defra are back-tracking on the March 2020 ‘Next Steps’ policy in favour of continued forms of supplementary and low risk area culling in existing and new areas, as directed by the Defra Chief Veterinary Officer. The methods for selecting ‘cluster areas’ for badger culling is not prescribed and effectively leaves a free hand for culling at the CVO’s discretion aided by industry advisors.

All previous Defra badger cull consultations have resulted in implementation of the policies as set out in the consultation, whatever the responses have been. Defra have made it clear that they will consider ‘group’ objections differently to personal objections.

We feel this consultation is unlawful and should be withdrawn and as such cannot recommend anyone responding until further advice has been received.

Consultation Foreword by Steve Barclay Secretary of State for Defra.

It is hard to know if the mistakes in new Minister Barclay’s foreword are unintended. It was probably written for him by Defra staff, perhaps the Chief Vet, who as we know struggles with science papers. On the back of the brand new APHA research he says “I want to be clear. A major element of this success has been the industry-led cull of badgers.  The latest evidence from the first 52 cull areas shows that rates of bovine TB breakdowns in cattle are down on average by 56% after four years of culling. This analysis has been published in a scientific journal after rigorous peer review. “

Leaving aside whether the peer review was rigorous and independent or not, Barclay, the Secretary of State for EFRA is attributing the decline in detected cattle herd breakdown incidence to four years of badger culling, as has the Defra Minster Douglas-Miller. This is now being repeated widely in farming circles. But the science Barclay refers to does not support this, even if it implies it in the abstract. There is a bit of speculation about it in the discussion, that is all.

Call this lies or misinterpretation, there really is no such clarity from ‘the latest evidence’. Even Cambridge’s Defra-funded James Wood had to correct the over-simplified abstract of the new APHA paper (Birch et al) for a piece in last weeks  Veterinary Record. The misleading abstract should be a simple retrospective corrective edit for the journal, along the lines of other government funded bTB science. We will see.

On this point Defra boss Douglas Miller had been making  the ‘56% benefit’ claims  for months, based on a preprint that was corrected when published. To be really, really clear, what the peer reviewed published science says is that it is not possible to directly attribute the fall in cattle herd bTB breakdowns to badger culling. It could all be due to cattle testing or other factors. Recent alternative published peer-reviewed analyses strongly suggest that this is the case (Langton et al). The courts could be interested in the misrepresentation of science by the Minister.

Also not mentioned in the consultation is the fact that the statistical code for the Birch paper (instructions on how it was analysed) is not included in the supplementary information published with the paper, so it can’t be checked. Requests to the author for this code and to the Minister have not yet been successful. Defra have received a legal letter asking for it promptly but it had not arrived by the noon deadline on 20th March. There are several things about the analysis that look a bit odd and which deserve further scrutiny, so supply of information to be able to re-run the analysis is critical to an ‘intelligent and informed response’ to the 14th March consultation.

PART A – BACKGROUND

This gives the usual statistics of change in bTB levels around the issue. There are comments about an ‘adaptive policy’, ‘banking the benefits’ and ‘striking a balance’, but none of these claims are scientifically evidenced and are mostly seem to be throw-away blah from Defra staff and the shambolic BTB Partnership.

PART B – PROPOSAL 1

The report text then switches from its assertive attitude in the Ministers statement to be a bit more careful. It says: “5.2. The policy of badger culling, which has been in place since 2013, is highly likely to have contributed to this significant reduction in the disease.” Not sure any more then? Still wrong – should have said ‘could be’. Paragraph 5.3 implies the reduction of bTB breakdown incidence is due to badger culling, which is an incorrect assumption and not borne out by the Birch study, as was also made clear by Oxford’s Prof David McDonald’s analysis earlier this year. A more detailed look at Birch et al.(2023) pre-print is available here and here.

Defra then repeat their outburst from two years ago, rejecting independent peer reviewed science in a top Vet journal, that suggested badger culling brings no response to bTB control, as follows:

“We acknowledge that this analysis has been challenged by certain groups opposed to culling who analysed the publicly available data from cull areas up to 2020 11. These groups concluded that culling had no effect on bTB in cattle. This peer-reviewed analysis was published in the Veterinary Record journal in March 2022. The Defra Chief Scientific Adviser (CSA) and UK Chief Veterinary Officer (UK CVO) assessed this paper and found the analysis to be flawed. The UK CVO and CSA response (and a later correction) was published in the Veterinary Record12,13 although the authors reject the criticisms of the UK CVO and CSA 14.“

An outburst that APHA have still, after 24 months, failed to demonstrate scientifically – despite holding all the data, in secret. It would be possible for APHA to simply compare farms in culled and unculled areas in multiple ways to test for the efficacy of culling. Why have they not done this? Is it because they do not get the result that they are desperately seeking to support the policy? The signs are that internally, APHA  actually know they are wrong. One senior insider has said privately in response to the consultation “the momentum created by Godfray is being stifled as DEFRA considers that the solution is too difficult and too expensive….. convincing themselves that the cull has worked to avoid the embarrassment of their mistakes.”

What are the future badger killing consultation proposals in general?

  • Construct a narrative that ‘badgers are a part of the local disease problem’ using circumstantial evidence from dead badger surveys.
  • Remove the all-important ‘exceptional use’ requirement of the March 2020 Next Steps policy, so badger culling can expand across the whole of England (HRA/EDGE/LRA), as before.
  • Change the term ‘cull area‘ to ‘cluster area’. Talk about ‘targeted badger intervention’ when all that has happened is cull areas have been renamed.
  • Rename ‘cull company’ as ‘licence holder’ who will appoint gunmen for both cage shooting and cruel free shooting, and it appears, badger vaccinators (Para 5.30).
  • Allow unlimited cluster areas to be licensed for culling each year (Para 5.18). Licenses to last for one year at a time.
  • Keep the 100% culls in the Low Risk Area using the ‘’Hotspot’ approach, which remains more or less the same, and a model for ‘clusters’. Death by APHA terminology.
  • The public will continue to pay for the licensing operation and monitoring, as well as the cost of policing culls, and support with costs incurred by industry when carrying out badger vaccination (Para 5.35).
  • Defra infer that the objective of a targeted badger intervention policy would be to secure disease control benefits by reducing the potential for infectious contacts between badgers and cattle in cluster areas ”before eradicating infection in cattle herds within the affected cluster” (Para 5.7).  This has not previously been suggested, i.e. badger culling is a prerequisite for cattle measures to be able work. This is not borne out by scientific literature and evidence. As such it is speculative and an attempt to mislead consultees regarding disease epidemiology.

How will cluster/cull areas be chosen?

  • APHA say cattle movement data and use of ‘whole genome sequencing’ of dead cattle and badger samples will inform the process. But it is unclear how, and sight of the method is lacking. There is no mention of the detailed independent report from 2023. that found the process failed and unfit for purpose. How cluster areas are chosen  can be changed at any time it seems, a free reign for government.
  • “Breakdowns that could be caused by high-risk cattle movements will then be removed, to increase the accuracy of identifying areas where badgers are a part of the problem in the spread of disease to cattle.“ This does not make sense, why would the source matter if cattle have gone on to infect badgers. This does not even follow the twisted APHA logic.
  • Cull supremo Christine Middlemiss, the UK CVO, will oversee deciding which clusters should be eligible for badgers to die. She might use ‘epidemiologists and veterinary science experts’ from the Bovine Tuberculosis Partnership – the closed cabal of mostly farmers and cull operatives that helped to refine these ideas. That works in secret and seems largely unaccountable.
  • Defra apparently have a magic bullet up their sleeve: “We are developing a surveillance and monitoring system which, when fully implemented, would allow for an assessment of the level of risk that local badgers may pose in a cluster.” We need to see and understand this pipe dream to be able to consider it.
  • The culling season will be relaxed from a fixed duration of around 10 weeks to the free-for-all allowed in Supplementary and Low Risk Area culling, to enable maximum culling of badgers. It seems to faciliate 100% culling if you want it, through to the end of January of the following year.

Badger vaccination – the new bolt-on

  • The failed BTB Partnership has apparently indicated that badgers should not be vaccinated before being culled in the HRA or Edge (Para 5.17) and the LRA (Para 5.21) because it would take too much effort.
  • After culling for two years or more, any surviving/recolonizing badgers may be vaccinated, and this is a condition of culling. Although government may fund vaccination, it appears farmers do not want to vaccinate badgers.

Note, in Cumbria it looks as if badger numbers bounce back within very few years, as they have in Gloucestershire, so the number of badgers needing vaccination is going to be massive. Especially as loads of areas that still have bTB embedded have been coming out of supplementary culling and are now due for badger vaccination according to the APHA vision. Or are government going to wait for badger numbers there to build up and cull large numbers again later? Or launch a military-scale exercise to get them vaccinated? Has anyone really thought this through? Thousands of people, tens of thousands of cages and vaccines. Or will it be a token effort to cover for just more culling?

This consultation, if taken at its word, could be a mandate for massive amounts of badger vaccination starting this year with no culling. But no, the unproven ‘shoot then vaccinate in new areas’ idea is pushed hardest, no doubt to win the anti-badger audience:

  • “The licence holder would also need to demonstrate, that it is able to vaccinate badgers in the year immediately after culling is stopped and for (typically 4) years as advised by the UK CVO (para 5.32). They must establish, with government support, cage trappers and lay vaccinators, organising training or securing a contractor to undertake badger vaccination. “

Other changes:

Defra will take over licensing from Natural England (Paras 5.14 and 5.27), but NE will still be responsible for saying that ecological impacts are barely significant and will be waving culling through without properly monitoring its impacts on designated sites. While claiming that it does. Tony Juniper’s cull-championing charade looks set to continue. Tim Hill who claimed badger culls to be a success each year is leaving this summer though.

Un-culled areas can have farm biosecurity measures and badger vaccination if they wish. APHA think “The available evidence suggests that the factors affecting the transmission of M. bovis between badgers and cattle are highly context-specific and dependent on many interacting factors at a local level.” There is no scientific evidence base or consensus for this claim – unless it is hidden from view..

Nothing changes:

Any decision by the Secretary of State on introducing licensed badger control under a targeted badger intervention licence will be informed by the scientific evidence and veterinary advice available, experience from the licensed badger control operations to date and responses to this consultation.” (Paras 5.24).
How will this be done and made available for scrutiny?

Previous economic assessments of wildlife control policies indicated that badger culling largely represents positive value for money.” (Para 5.22).
This is simply not properly evidenced, with unexplained lumped figures, and the public are almost certainly being misinformed. Defra have no idea about the effect of measures on the true burden of disease in cattle, embedded and undetected.

PROPOSAL 2: Licence and associated conditions for badger culling under a targeted badger intervention policy 

The size of future cluster areas is unclear but may be similar to existing cull areas – over 100 sq km. Within cull areas, Defra “will make decisions on the level of accessible land on a case-by case basis, taking into account such specific circumstances such as topography, land use and badger sett surveys or any other matter that is considered relevant” (Para 5.33).
The CVO has recently claimed (on Farming Today) that cluster culling is not the 100% culling approach of LRA culling (the proposed epi-culling model). But it looks like it. As cluster areas get bigger, the aim will be to kill 100% of badgers over available land which may be more restricted than was the case in the Cumbia and Lincolnshire cull areas. The system is not as well described as the 2018 low risk area culling methodology. It looks fairly similar, but in areas where permission to cull and vaccinate will be harder to obtain. There is no binding agreement for a minimum 6 years cull, and vaccinate it is all on trust. The bad idea is badly planned.

Strange?

Paragraph 5.36 states: “.. if a cluster overlaps with an area that has completed intensive or supplementary badger control within the last three calendar years, there would be no funding requirement.” This presumably means no need of disclosure of available funds to cull. “If the interval is longer than this, the licence holder will need to demonstrate that it has access to funds which are sufficient to carry out culling operations in eligible clusters for at least two years,”  This might imply that there will be an overarching licence holder for more than one cluster. It’s all a bit unclear. Why would a supplementary culling area not go straight to vaccination only, or is the aim just an extension of supplementary culling? Why not go straight to vaccination? The text is hard to unravel and looks ill-prepared.

“Culling in response to bTB outbreaks in the Low-Risk Area of England would continue to be permitted on the same terms as introduced in 2018, on an individual licence basis”. But LRA culling is the model for epi-culling which was not warranted and has failed. Just recently a new breakdown in the area.

Methods for the HRA /Edge seem to imply it will not be LRA-style culling (with a buffer area etc) but more like a hybrid with supplementary culling, according to cluster area size. Will cluster areas cull to hard boundaries or not? Thus, the consultation presents a lack of clarity and ambiguity to a degree that makes meaningful response impossible.

PROPOSALS 3 and 4

These relate to cattle purchasing and cattle movement monitoring and are not considered here.

Annex A: Wildlife disease control – Progress since 2020

Defra states (Para 1.10.) “We proposed to pilot the vaccination in areas as part of a phased approach. APHA has recruited two cohorts of full-time vaccinators in 2022 and 2023, who have been undertaking badger vaccination in several areas across the country, including in five former cull areas. These areas vary in size from 15 to over 350 km2, with more than 1,500 badgers vaccinated in England by APHA in total in 2023.”

There is absolutely no chance of vaccinating badgers in more than a very few cluster areas for multiple reasons, so this consultation is misguided not only in its scientific evidence base, but also regarding the feasibility of vaccination ever happening other than at the existing token scale. A phased approach that will fizzle out.

Information on  the pilot exercise in Cumbria is sketchy, and it is not possible for the public to understand exactly what is being done: the recovery rate of badgers, how many vaccinated badgers have been shot and how many vaccinated twice, or how many badgers have bTB of different strains. The consultation is describing an unevidenced process that is more hope than reality, that it cannot afford and will not seek to properly implement, for which there is no evidence that it will have any effect at all, and breaking multiple scientific and ethical veterinary and good practice guidelines. It is representative of a failed policy.



Veterinary Record exposes yet more government bovine TB failings

The respected journal Veterinary Record included two short News and Reports articles on government bovine TB news last Friday 15th March, just a day after their consultation to ‘evolve badger cull policy’ was announced.

The first covered a story we have written about in our blog (here) regarding the downsizing of the government bTB partnership. Member Dick Sibley was effectively sacked from the partnership, and VR comments:

“Sibley said he had been sacked after challenging Defra on the effectiveness of its testing and eradication programme, particularly the south west of England where he is based. He said the downsizing of the partnership would result in a decrease in challenge and debate.”

Another member who was removed from the partnership commented “They don’t want the partnership to come up with its own ideas, they want Defra’s ideas to be rubber-stamped by the partnership.”

The short article ends with the usual Defra quote about what a serious disease bovine TB is and what a difficult and intractable animal health challenge. It concludes “…… we are now able to move on to the next phase, including wider badger vaccination, alongside improved cattle testing, and work towards deployment of a cattle vaccine.”  There is no mention of badger culling in the statement by Defra’s spokesman. This is despite the fact that is was  published a day after the consultation was launched, a consultation in which Defra’s outlines its intention to continue an adapted, unrestricted, and less controlled form of intensive culling. They fail to mention it at all.

The second article “APHA study looks at the effect of badger culling on bTB”, is a short report on the newly published paper by APHA staff member Colin Birch and colleagues. The claims of the paper are reported, but notably, James Wood was quoted as saying “the badger control programme has been associated with increased use of more stringent cattle controls, including the use of gamma interferon assay in infected herds and promotion of biosecurity, which means that the attribution of the full effect to a single intervention is not possible.”

In fact that should be, the attribution of any effect to a single intervention is not possible. The reality is that Birch et al 2024 on which the consultation rests heavily, fails to prove any benefit attribution to badger culling at all. The Defra Minister Lord Douglas-Miller and Secretary of State Steve Barclay have, as a result of APHA’s failings, misled the public. They need to withdraw the consultation immediately.